Protection provider identifier “Non-applicable” for natural persons
The different parts of the AnaCredit Reporting Manual do not seem to be fully consistent with regard to the reporting of protection provider identifier.
In particular, Section 18.104.22.168.2 of Part I of the AnaCredit Manual indicates that “Not required” is reported while Section 9.4.1 of Part II states that “Non-applicable” is reported in instances of natural persons acting as protection providers to non-natural persons.
While the concepts of “Not required” and “Non-applicable” may indeed seem similar, they are interpreted differently. As a general rule, where the information pertaining to an attribute of AnaCredit is not reported as a consequence of the derogations in the AnaCredit Regulation, the value “Not required” is reported.
In contrast, the value “Non-applicable” is reported if the attribute is not derogated in accordance with the AnaCredit Regulation but no appropriate value in fact exists or can be reported because the concept itself is not applicable in a certain situation (following the clarifications provided in the AnaCredit Reporting Manuals).
For that reason, as the AnaCredit Regulation does not envision any derogations in relation to the data attribute “protection provider identifier”, the value “Non-applicable” is reported in accordance with the clarifications in Section 9.4.1 of Part II of the AnaCredit Manual in cases where the protection provider is a natural person.